What type of situations prompted English judges to create the concept of constructive possession?

Question

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The concept of constructive possession was created to address the situation of "trespass in the taking," where a person takes possession of someone else's property without physically removing it from its original location. For example, if someone takes something from a store shelf and puts it in their pocket without paying, they have constructively possessed the item even though it's still physically located in the store. This concept is particularly relevant in cases of theft and shoplifting.

What Type of Situations Prompted English Judges to Create the Concept